A Brief History of U.S. Approaches to Corporate Tax Integration and Some Lessons

16 Pages Posted: 14 Jul 2022 Last revised: 19 Jul 2022

See all articles by George K. Yin

George K. Yin

University of Virginia School of Law

Date Written: July 12, 2022


This essay, to be included as a chapter in a volume on corporate taxation, briefly reviews U.S. efforts to achieve corporate tax integration, focusing especially on the Civil War years when enduring problems first surfaced and Congress approved four integration approaches in three years. The review highlights the important role corporate distribution policy has played in solving the integration puzzle. By distributing or retaining earnings, corporations can either advance or block integration objectives. Somewhat counterintuitively, the historical experience suggests the most feasible way to satisfy integration’s goals may be to retain two moderate and comparable, though separate, taxes on corporate income.

Keywords: corporate tax integration, dividend exclusion, shareholder credit, dividends paid deduction

JEL Classification: H20, H25, K22, K34

Suggested Citation

Yin, George K., A Brief History of U.S. Approaches to Corporate Tax Integration and Some Lessons (July 12, 2022). Virginia Public Law and Legal Theory Research Paper No. 2022-47, Virginia Law and Economics Research Paper No. 2022-13, Available at SSRN: https://ssrn.com/abstract=4162912

George K. Yin (Contact Author)

University of Virginia School of Law ( email )

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Charlottesville, VA 22903
United States
434-924-7025 (Phone)
434-924-7536 (Fax)

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